Case: Attorney’s Penalties For Failing to Timely File, Pay Employment Taxes Were Abated Due to Reasonable Cause (T.C. Summ.) (IRC §6651)

A 92 year old solo attorney practitioner’s failure to timely file returns and timely pay employment taxes was due to reasonable cause and not willful neglect, such that he wasn’t liable for additions to tax for the periods in issue, the U.S. Tax Court held in a summary opinion, granting Taxpayer’s request to abate the penalties. Taxpayer was in the midst of closing a law practice due to his declining health and advanced age. Taxpayer had effective systems in place that failed him in his final years of law practice only because he was unable to supervise his assistant properly. ...